NANCY MAISTO
Email: *********@***.*** 718-***-****
EXECUTIVE PROFILE
• Seasoned compliance and supervision professional that skillfully balances the firm’s risk with the need to drive business results
• Proven people leader with high employee satisfaction and loyalty
• Proven Project Management skills: initiation, planning/design, production/execution, monitoring/control, and closing/deliverables.
• Extensive experience in designing and executing process and organizational change
• Thorough understanding of industry regulations and experience in their practical application in the wire house and independent business models
• FINRA Series 3, 7, 9, 10, 31, 63 and 65 licenses
• Health and Life Insurance license, Rule 144 Specialist
• Self-directed professional with strong initiative and organizational skills
• Proven ability to analyze, utilize industry standards and employ sound judgment to draw conclusions regarding the status of an agent's compliance program
• Member of various CCO round table discussion groups
• Participate in regulatory discussions involving new regulations
• Member of the National Society of Compliance Professionals (NSCP) and SIFMA Compliance Legal Society
Compliance Consultant, New York March 2012 - Present Corporate consulting services to assist asset management, investment advisers, hedge funds, funds of funds, private equity, banks and broker dealers on a wide range of compliance. Services offered include but are not limited to:
• Compliance: SEC, FSA, FINRA, NFA, FinCEN, OCC and State regulatory compliance; anti-money laundering; reporting requirements; BSA, AML, OFAC, KYC & FATF compliance for various hedge funds and fund of funds; Anti-money Laundering (AML) policies & procedures to establish Accredited and Qualified investor status.
• Provide current information on the regulatory environment,
• Foster a common vision and language related to compliance.
• Risk rank applicable regulations.
• Provide guidance on policies, procedures and training.
• Support business compliance liaisons in communicating compliance matters to their business partners.
• Provide input to compliance monitoring on areas to monitor and frequency of coverage.
• Review results of monitoring, audit and other assurance activities to summarize compliance status for senior management.
• Support Management and Audit Committee reporting as needed.
• Support relationships with government regulators that examine company records.
• Provide professional expert knowledge of policies, processes and controls established by the First Line of Defense to achieve and sustain RIsk-based Compliance with applicable laws and Regulatory Requirements.
• Develop, plan, maintain and manage critical business communications outlining regulatory changes.
• Risk Scoring Compliance.
• Mitigate risk exposure by identifying activity that poses potential for significant regulatory and/or reputational damage.
• AML Project Manager.
• Support Volcker Rule implementation activities within the Compliance Group.
• Identify areas where Dodd-Frank standards can be enhanced and assist in their effective implementation.
• Work with Legal and Outside Counsel to interpret the applicability of Dodd-Frank to the bank's various businesses on a cross-divisional basis.
• Assist with regulatory examinations and inquiries related to Dodd-Frank.
• Direct compliance analyst teams on the Investment Company Act of 1940 and Investment Advisers Act of 1940.
• Review, provide corrective action and approve marketing material utilizing Compliance 11.
• Conduct Annual Reviews and testing for both B/Ds and RIAs.
• Update Compliance Manuals.
• Surveillance of investment guidelines; interpret complex subjects including ’40 Act
• Compliance and ethics monitoring and testing.
• Oversight of independent money managers, international banks, and broker dealers
• Provide guidance and participation of Regulatory Compliance, SEC filings such as ADV and Form PF.
• Prepare and review policies and procedures, determine the nature and scope of the project, develop the scope statement, identify deliverables and create a work breakdown structure, manage project execution, develop strategy to align development with the organization’s broader objectives.
• Utilize a rigorous process of defining client requirements.
• Formulate analysis and project execution approaches in coordination with technical teams, taking into account business priorities, integration points across projects, infrastructure, system interfaces, and data.
• Analyze potential risks/benefits involved in using specified technology solutions to address business requirements.
• Develop project plans and define project purpose, clear roles, tasks, milestones, and measures of success.
• Manage project-estimating activity working across multiple teams including infrastructure teams.
• Define and document project risks and mitigation plans.
• Lead project teams in successful execution and delivery of equity derivatives compliance testing for firms ranging from half a billion to 1 billion in AUM for assignments ranging from 6 to 8 months.
• Conduct project/phase kick-off meetings to communicate individual roles and project expectations.
• Monitor projects on an ongoing basis, evaluating progress and quality, managing risks / issues, and taking corrective action as necessary.
• Lead post-implementation reviews evaluating project results, including client satisfaction. SAFRA, New York January 2011 – February 2012
Chief Compliance Officer and Designated AML Officer
• Managed initiatives focused on enhancing the firm's AML transaction monitoring capabilities and managed special projects.
• Monitored adherence to client guidelines, regulatory requirements and internal policies
• Performed portfolio compliance reviews of third party money managers, and Alternative Investment strategies.
• Supported affiliates globally to ensure appropriate levels of information sharing.
• SAFRA specialized in various asset classes, including real estate securities, real assets, large cap value equities, globally listed infrastructure, preferred securities and alternative strategies.
• Analyzed issues from regulatory exams and audits; reports on trends and opportunities for improvements.
• Monitored and tested both the broker-dealer, bond and asset management activities.
• Detailed understanding of complex OFAC regulations.
• Reviewed and developed the Wealth Management Program, oversight of both non- discretionary and discretionary services program.
• Developed and tested Investment Advisor program.
• Provided ADV parts 1 and 2 and ADV 2B updates.
• Provided guidance to our foreign affiliates regarding the coordination for both US and foreign regulations.
• Reviewed and updated compliance manual policies and procedures to comply with all securities laws, regulations and directives issued by the SEC and communicated material changes to all company employees.
• Advised on a broad range of compliance matters, which were associated with the firm’s international affiliates.
• Kept the company current on recent compliance and legal issues, trends, and upcoming developments.
• Reviewed and improved internal marketing materials and disclosures.
• Documented adherence to the requirements of the 1934 Act, Investment Advisers Act and Investment Company Act, and the Advisers Act of 1940.
• Advised on relevant product areas (research, investment banking capital markets, sales and trading).
Gilford Securities, New York May 2010 - January 2011 CCO and Designated AML Officer -SVP
• Proven experience developing partnerships with and successfully coordinating across a multitude of stakeholders from business, technical and vendor teams.
• Worked effectively with colleagues at various levels of the organization.
• Facilitated meetings among stakeholders with diverse and sometimes conflicting points of view.
• Researched and resolved issues independently while working across teams to acquire needed information.
• Organized/managed multiple priorities and projects coupled with the flexibility to adapt to changes in a fast-paced environment.
• Developed high quality documents and presentations for multiple audiences including project plans, solution alternatives, and project execution approaches.
• Provided guidance and maintain compliance programs for broker dealer, investment advisor, hedge fund and mutual fund.
• Contact person for FINRA and SEC audits. Coordinated, executed, and successful completed compliance projects with the support of compliance team.
• Project management: worked collaboratively with teams and align enterprise resources.
• Managed risk-based monitoring for unusual activity, including: detection, investigation, suspicious reporting to law enforcement agencies, documenting the file with supporting documents, deciding either to close the account or continue monitoring.
• Investigated potential sanctions, hits on underlying clients generated from automated alert software.
• Provided training relating to money laundering / financial crime prevention and maintain accurate records.
• Procedures including documentation reviews, data review and prepared spreadsheets for internal/external audits.
• Detailed understanding of complex OFAC regulations.
• Reviewed and developed the Wealth Management Program, oversight of both non- discretionary and discretionary services program.
• Developed and tested Investment Advisor program.
• Provided ADV parts 1 and 2 and ADV 2B updates.
• Provided guidance to our foreign affiliates regarding the coordination for both US and foreign regulations.
• Reviewed and updated compliance manual policies and procedures to comply with all securities laws, regulations and directives issued by the SEC and communicated material changes to all company employees.
• Advised on a broad range of compliance matters, which were associated with the firm’s international affiliates.
• Kept the company current on recent compliance and legal issues, trends, and upcoming developments.
• Reviewed and improved internal marketing materials and disclosures.
• Documented adherence to the requirements of the 1934 Act, Investment Advisers Act and Investment Company Act, and the Advisers Act of 1940.
• Advised on relevant product areas (research, investment banking capital markets, sales and trading).
• Performed needs analysis and establish the firm element.
• Reviewed error reports, OATS and trace reports.
• Conducted weekly review of the trading desk.
• Reviewed mutual fund switch letters and breakpoints.
• Reviewed fixed income transactions.
• Monitored trade runs and exception reports.
• Audited accounts for suitability and excessive commissions. Gunn Allen Financial, New York April 2003– May 2010 Compliance Officer
• Filed suspicious activity reports (SARs) when necessary.
• Reviewed OFAC list as a part of the customer identification (CIP) procedure AML Officer.
• Performed Quality assurance testing for BSA/AML program.
• Worked closely with the Chief Compliance Officer in completing the annual compliance program testing in accordance with Rule 206(4)-7 and Rule 38a-1; including annual compliance meetings with department heads to assess the effectiveness of established compliance processes and controls.
• Responsible for budget management, tracked expenses and minimized exposure and risk.
• Performed surveillance and conducted investigations to detect violations for both RIA and B/D.
• Performed needs analysis and establish the firm element.
• Reviewed error reports, OATS and trace reports.
• Conducted weekly review of the trading desk.
• Reviewed mutual fund switch letters and breakpoints.
• Reviewed fixed income transactions.
• Monitored trade runs and exception reports.
• Audited accounts for suitability and excessive commissions.
• Monitored new accounts to ensure they are opened in accordance with company policy, and procedures, applying the 1940 Act and KYC principles.
• Established, tested and monitored program for regulatory compliance.
• Conducted compliance risk assessments of business units.
• Monitored regulatory updates for inclusion in monthly regulatory highlights disseminated firm wide.
• Recommended action regarding compliance aspects of products.
• Reviewed mutual fund switch letters and breakpoints.
• Reviewed and approved advertising and sales literature.
• Conducted reviews of compliance procedures to determine effectiveness.
• Conducted oversight reviews.
• Monitored trade allocations, trade errors, trade booking issues and best execution. Morgan Stanley, New York January 1995 – April 2003 Compliance Officer
• Responded to requests from various departments throughout the firm, including Portfolio Management, Client Service, Internal Audit and Operations.
• Advised the Investment team, Risk and Client Service with questions.
• Worked closely with the Chief Compliance Officer in completing the annual compliance program testing in accordance with Rule 206(4)-7 and Rule 38a-1; including annual compliance meetings with department heads to assess the effectiveness of established compliance processes and controls.
• Assisted with the coordination and management of SEC examination of the firm’s advisory and mutual fund business.
• Conducted compliance training for brokers at this branch.
• Evaluated internal controls and anti-money laundering compliance programs.
• Performed surveillance of the rules under the Investment Advisers Act of 1940 and Investment Company Act of 1940.
• Provided guidance to our foreign affiliates regarding the coordination for both US and foreign regulations.
• Followed up with wealth management agents concerning review findings.
• Reviewed all marketing material including wrap products for compliance to regulatory guidelines.
• Reviewed mutual fund switch letters and breakpoints.
• Worked with legal counsel and operations department to review adherence to regulators.
• Conducted trade surveillance for both investor account and employee account. OTHER RELATED EXPERIENCE
Navy Resale, Internal Audit Administrator (8 years) Ernst and Young, Auditor (2 years)
EDUCATION
St. John’s University, New York graduated with Honors - Bachelor of Science in Accounting, Economics
SKILLS
Proficient in Microsoft applications and Web based tools